Ireland's anti-money laundering regime has moved substantially closer to the EU's reinforced supervisory model. Amendments to Ireland's primary anti-money laundering legislation – which transposed the latest EU directives into domestic law – took full effect in early 2025. Companies that have not yet reviewed their internal compliance programmes face a sharply elevated risk of supervisory scrutiny, enforcement action, and restrictions on access to banking services.
Ireland's updated AML rules impose stricter know-your-customer (KYC) obligations, expanded beneficial owner verification requirements, and enhanced due diligence duties on designated businesses. The changes apply to a broad range of entities including credit institutions, payment firms, legal professionals, accountants, and certain corporate service providers. Companies must bring their compliance programmes into conformity without delay, as the Central Bank of Ireland and other competent authorities have signalled active enforcement from the first quarter of 2025 onward.
This alert identifies which business categories are affected, outlines the threshold criteria that trigger enhanced obligations, and sets out the immediate steps international companies operating in Ireland should take now.
What changed – the regulatory development and its effective date
Ireland's anti-money laundering legislation was amended to align fully with the EU's sixth anti-money laundering directive and related regulatory technical standards. The updated rules became operative in January 2025.
The most significant shifts involve three areas. First, the definition of beneficial owner has been tightened. The threshold for identifying a natural person as a beneficial owner remains tied to ownership or control, but regulators now require entities to look through multi-layered structures more thoroughly. Passive reliance on corporate registers is no longer sufficient. Active verification – through documentation, cross-referencing, and reasoned written conclusions – is now mandatory for all designated persons.
Second, the rules governing correspondent banking relationships have been revised. Irish credit institutions that maintain or establish correspondent banking arrangements with respondent institutions outside the European Economic Area must now conduct enhanced periodic reviews. The frequency of those reviews has been shortened, and documentary evidence of the respondent's own AML controls must be retained on file.
Third, the conditions under which a credit facility may be extended to a new customer have been updated. Designated credit institutions must complete full KYC verification before the first disbursement. Provisional facilities pending documentation are no longer permissible for higher-risk customers as defined under the updated risk classification guidance issued by the Central Bank of Ireland.
The Central Bank of Ireland (Ireland's primary prudential and AML supervisory authority for financial institutions) and the Law Society of Ireland and Chartered Accountants Ireland (responsible for legal and accounting professionals respectively) have all published updated supervisory expectations in line with these changes.
For international companies active in capital markets, the implications extend to how counterparty due diligence is structured. Our capital markets practice in Ireland covers the interaction between AML obligations and securities transaction documentation in detail.
Who is affected – threshold criteria and business categories
The updated regime applies to all designated persons (the Irish legislative term for entities subject to AML obligations). The following categories are directly in scope.
- Credit institutions and payment service providers licensed in Ireland or passporting into Ireland from another EU member state
- Investment firms, fund administrators, and collective investment scheme managers
- Legal professionals – solicitors and barristers – when involved in financial or real estate transactions
- Accountants, auditors, and tax advisers providing services to corporate clients
- Corporate service providers, trust companies, and registered agents
For non-financial businesses, the trigger is transactional. A company outside the financial sector becomes subject to AML obligations when it conducts or facilitates a transaction above the cash threshold set in Irish anti-money laundering legislation. Alternatively. When it provides a service that falls within the defined scope of designated activities.
International companies establishing or maintaining an Irish subsidiary should pay particular attention to bank account opening procedures. Irish banks have updated their internal KYC questionnaires to reflect the new regulatory requirements. Requests for documentation on the beneficial owner, the source of funds, and the anticipated transaction profile are now more detailed than in prior years. Incomplete submissions result in delays of several weeks – and, in some cases, refusals.
To receive an expert assessment of your company's AML exposure in Ireland, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions and compliance timeline
Companies with operations, subsidiaries, or banking relationships in Ireland should treat the following as a priority checklist. The window for voluntary remediation – before supervisory inspection cycles begin – is narrowing.
- Audit your beneficial owner records. Confirm that the natural persons who ultimately own or control your Irish entity are identified, verified against source documents, and recorded in both your internal register and the Irish Register of Beneficial Ownership (RBO). Discrepancies between internal records and the RBO are a primary trigger for regulatory scrutiny.
- Update your KYC files for existing customers and counterparties. Periodic refresh obligations now apply on a shorter cycle for higher-risk relationships. If your last review predates January 2025, treat it as overdue.
- Review your AML policy and risk assessment documentation. The updated rules require written, entity-specific risk assessments. Generic template policies are unlikely to satisfy supervisory review. The assessment must address your specific business model, customer base, and geographic exposure.
- Train relevant staff. Designated persons must ensure that employees involved in onboarding, transaction monitoring, and customer relationship management have received updated AML training that reflects the 2025 legislative changes.
- Assess correspondent banking and credit facility documentation. If your Irish entity is a credit institution or works through one, verify that correspondent banking files and credit facility onboarding checklists have been updated to the current standard.
Companies that have recently completed or are planning a bank account opening in Ireland should expect requests for enhanced documentation packages. Preparation in advance significantly reduces the risk of delays or adverse decisions.
The broader banking and finance compliance context for Ireland – including licensing requirements and ongoing supervisory obligations – is covered in our banking and finance practice page for Ireland.
For companies monitoring comparable AML developments across other EU jurisdictions, our alert on AML updates in Portugal provides a useful parallel reference.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our banking and finance practice covers AML compliance, regulatory licensing, credit facility structuring, and correspondent banking arrangements in Ireland and across the EU. We work with financial institutions, corporate groups, and international businesses that need practical, cross-border legal counsel on regulatory matters. The firm combines Portuguese civil law expertise with English common law tradition – an advantage when advising clients whose operations span multiple legal systems. Our attorneys have experience before the Central Bank of Ireland and equivalent supervisory authorities across EU member states. Engaging a lawyer in Ireland with cross-border AML experience can make a material difference to the outcome of a supervisory review. As an international law firm in Ireland, Ferraz & Whitmore provides the depth of regulatory knowledge that domestic and multinational clients require. To discuss your company's AML compliance position in Ireland, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.
Published: February 21, 2026
Author: Edward Whitmore – Senior Partner, Dispute Resolution
Edward Whitmore is a Senior Partner at Ferraz & Whitmore specialising in international commercial arbitration, enforcement of foreign judgments, and complex litigation. With a background spanning English common law and civil law systems, he represents multinational clients in high-value cross-border disputes.